Motion For Extension Memoranda 622w5z

Republic of the Philippines REGIONAL TRIAL COURT Judicial Region Branch 00 Manila BBB,

Civil Case no. 8176 Plaintiff-Appellant FOR: FORCIBLE ENTRY -versus-

AAA, Defendant-Appelle x- - - - - - - - - - - - - - - - - - - - - -x

EX PARTE MOTION FOR EXTENSION OF TIME TO FILE MEMORANDUM Plaintiff, by the undersigned counsel, and unto this Honorable Court, most respectfully states that: 1. On October 10, 2016, the Honorable Court issued an Order directing the parties to file their respective memoranda; 2. Counsel for the plaintiff received such order on October 12, 2016; 3. The plaintiff-appellant is in the process of bringing again the parties to mediation whereby an independent surveyor will be appointed this time by mediator instead of this honorable court; 4. The plaintiff-appellant is willing to enter into another compromise agreement with the defendant-appellee depending on the result of the relocation survey of the property; 5. As such, the undersigned counsel is constrained to request for an additional period of thirty (30) days from the expiration of the period to file memoranda, within which to submit Plaintiff’s memorandum or parties’ compromise agreement; 6. This Motion is not intended for delay but solely due to the foregoing reasons.

P R AYE R WHEREFORE, Plaintiff-Appellant most respectfully prays that the Honorable Court give her an additional period of thirty (30) days from October 27, 2016, within which to submit her memorandum or the compromise agreement of parties. Other reliefs, just and equitable, are likewise prayed for. RESPECTFULLY SUBMITTED this 19th day of October 2016, in Daet Camarines Norte, Philippines.